Coldeal Privacy Policy

[Special Reminder] Please carefully read the Coldeal Privacy Policy (especially the bold and underlined content) and make sure you understand our rules on the processing of your personal information. During reading, if you have any questions, you can contact us through the contact information we provided in the tenth part of the text. If you do not agree with any of the terms in this privacy policy, you should stop accessing Coldeal immediately.

Release date:

Effective date:

Foreword

Beijing Infinity Data Technology Co., Ltd. (hereinafter referred to as "Infinity" or "we") attaches great importance to the privacy and protection of personal information of users. When you are using products and / or services of our China frozen product industry integrated service platform (hereinafter referred to as "Coldeal" or "us", which includes six major businesses of international trade, cold chain logistics, online transaction, cold chain storage, supply chain, and frozen products processing, corresponding website http://www.cciinet.com, mobile application, WeChat official account, and WeChat Mini Program), we will collect and use your relevant information. We are willing to explain to you through the Coldeal Privacy Policy ("This Privacy Policy") how we collect, use, store and share this information when you use Coldeal products and / or services, as well as ways we provide for you to access, update, control, protect and delete this information.


This policy will help you understand the following:

1. How do we collect and use your personal information

2. How we share, transfer and publicly disclose your personal information

3. How do we protect your personal information

4. How do we protect minors' personal information

5. How do we use cookies and similar technologies

6. How do you manage personal information

7. How your personal information is transferred globally

8. Updates and notifications of privacy policy

9. Scope of privacy policy

10. How to contact us


If you use Coldeal products and / or services, or continue to use Coldeal products and / or services after we update this privacy policy (we will promptly prompt you to update), it means that you agree to this privacy policy (including updated version), and agree that we collect, use, save and share your relevant information in accordance with this privacy policy.


We strive to present this privacy policy in a concise, clear and understandable manner. In order to facilitate your reading and understanding, we have defined specific terms related to the protection of personal information, our business and organizational relationships. Please go to the "Appendix 1: Definitions" of this privacy policy to understand specific content of these terms, so that you can accurately grasp what we want to express to you.


Ⅰ How We Collect and Use your Personal Information


We will follow the legal, just and necessary principles to collect and use your personal information.


Specifically, in order to realize basic business functions, you should provide or allow us to collect and use your personal information according to our functional requirements. In addition to the basic business functions, you can independently decide whether to provide us with relevant personal information for using the extended business functions we provide. If you provide the personal information of others, please ensure that you have obtained the authorization of the relevant subject, and we reserve the right to check the legal source of such personal information at any time. To facilitate your understanding, the business functions we provide and personal information hence needed are listed below:


1. Information for Basic Business Function


You need to provide us with some personal information to help realize the basic business functions of "Coldeal". The information required for the realization of basic business functions is called “Essential Information”. If you refuse to provide these “Essential Information”, we will not be able to provide you with this basic business function and corresponding services. Information which is not required for the realization of basic business functions is called "Extra Information". If you refuse to provide such "Extra Information", it will not affect your use of our basic business functions.


The basic business functions of "Coldeal" include


1.1 User registration and authentication


In order to use Coldeal products and / or services, you first need to register for a Coldeal account. When you register, you need to provide us with your mobile phone number and the * password you will use at least. We will verify your identity by sending a SMS verification code. You need to provide us with the legal representative's name so that we can verify your identity with the other information you provide, and help you complete the enterprise identity verification. In addition, in the international trade service, you need to provide us with the name of your legal representative / person in charge and * ID card information to complete the merchant settlement certification. If you refuse to provide us with the aforementioned necessary information, you will not be able to complete registration and verification with Coldeal.


1.2 Product and / or Service Information Display and Search


In order to allow you to quickly find the goods and / or services you need, and to ensure that the goods and / or service information is correctly displayed, we may collect your mobile device IP addresses and services provider’s network ID when using our products and / or services to provide you with the best way to display product or service information. We will also use your personal information mentioned above for continuous improvement and optimization.


You can also find the goods or services you need precisely by searching. We will keep your search content to facilitate your repeated input or to show you the goods or services associated with your search content. Please note that your search keyword information cannot individually identify you, and it does not belong to your personal information. We have the right to use it for any purpose. Only if your search keyword information and your other information are mutually combined to use and hence you can be identified, during the combined using period, we will take your search keyword information as your personal information and process and protect it with your * search history in accordance with this privacy policy.


1.3 For Supply-demand Information Release


After you complete the registration, you can publish the goods / service supply and demand information in Coldeal. When you publish the aforementioned supply and demand information, according to the different needs of each business sector, you need to provide us with your contact name, contact number, location, * detailed address information. If you refuse to provide us with the aforementioned necessary information, you will not be able to successfully publish information for supply and demand. You can additionally fill in the email address and office phone information to ensure that the supplier / demand side can contact you more efficiently and conveniently, but not filling in the remaining information will not affect your release of supply / demand information


1.4 Drop an Order


When you use the six major services of Coldeal International Trade, Cold Chain Logistics, Online Frozen Product Transaction, Cold Chain Storage, Supply Chain, Frozen Products Processing to prepare for settlement of goods or services purchased in your shopping cart online or offline, Coldeal will generate an order for you to purchase the goods or services. You need to fill in at least necessary information of your contact person / consignee's name, * address and phone number in the order. And the order number, the goods or services you purchased, the amount of the payment you should pay and payment methods will be stated clearly in the order.


All the above information constitutes your * "order information", we will use your order information for your identity verification, transaction confirmation, payment settlement, completion of delivery, query for your order and to provide customer service consultation and after-sales service. We will also use your order information to determine whether your transaction is abnormal to protect your transaction security.


1.5 Pay

After you drop an order, limited to our commercial arrangements, you can only choose payment services provided by Coldeal's third-party payment institutions. The payment function itself does not collect your personal information, but we need to share your Coldeal order number and transaction amount with these payment institutions to enable them to confirm your payment instructions and complete the payment. For how we share your personal information, please refer to the description in section [2] of this privacy policy.


1.6 Delivery of Goods or Service Functions


When you drop an order and complete the payment online, limited to our commercial arrangements, you can only choose a third-party delivery company (hereinafter referred to as "delivery company") that cooperates with Coldeal to complete the delivery of your order. You know and agree that Coldeal's affiliates or delivery companies will use your order information in the above link to ensure that the goods you ordered can be delivered safely. For how we share your personal information, please refer to the description in section [2] of this privacy policy.


1.7 CustomerService and After-sales Functions



Our telephone customer service and after-sales functions will use your account information and order information.



To ensure the security of your account, our call center customer service and online customer service will use your * account information to verify your identity with you. When you need us to provide pre-sales consultation or customer service and after-sales service related to your order information, we will query your * access record or * order information. You may provide other information besides the above information when communicating with our customer service personnel, such as when you ask us to change * delivery address, contact person or contact number.



1.8 Send System Messages



During your use of Coldeal, we will collect your [account number, name, mobile phone number, business license] information and will send you important notices related to Coldeal products and / or services in the form of internal letters when necessary, including:



Announcement of software certification or managing software upgrade and maintenance.

Announcement of user agreement, settlement agreement, and privacy policy change.

Announcement of establishment, update or cancellation of service rules / systems.

Other service-related news, such as system greetings, holidays or special commemorative blessings, event news launched from time to time, notification of new service function, Coldeal product or service satisfaction survey invitation, transaction notification, and service suspended notification due to system maintenance.



Unless you cancel your account, or you will not be able to cancel the acceptance of these system messages related to the service without promotional nature.



1.9 Necessary Functions to Improve Our Products and / or Services



We may also obtain other information about you for the reasonable needs to provide services and improve service quality, including the relevant information you provided when you contacted customer service, the questionnaire response sent to us when you participated in the questionnaire, and related information we obtained when interacting with our affiliates and our partners. We may associate the information collected from your various devices so that we can provide you with consistent services on these devices. We may combine information from one service with information from other services in order to provide you with services, personalized content and suggestions.



1.10 Functions Necessary to Ensure Transaction Security



In order to improve the security of your system when you use our products and / or services, to more accurately prevent phishing website fraud and protect account security, we may know your * browsing information, * order information, your commonly used software information, device MAC address, operating system type, unique device identification code of software list (such as IMEI / android ID / IDFA / OPENUDID / GUID, SIM card IMSI information to determine the risk of your account, and may record some links we believe are at risk ( "URL") and * IP address. We will also collect your device information to analyze Coldeal system problems, count traffic and check for possible risks, and check when you choose to send us abnormal information.



2. Information for Expended Business Function



In addition to basic business functions, you can choose to provide us with some personal information to realize the extended business functions of "Coldeal", or help us use such information to improve service quality, and develop new products or services. If you refuse to provide information for extended business function, it will not affect your use of our basic business functions.



The information necessary to realize the extended business function is called "essential information". If you refuse to provide these "essential information", we will not be able to provide you with the extended business function and corresponding services. The information required for the realization of the extended business function is called "Extra Information". If you refuse to provide such "Extra Information", it will not affect your use of our extended business functions.



Coldeal's expanded business functions include:



2.1 Personalized Recommendation Function Based on Location:



You can authorize us to collect your location information (we only collect your geographic location at the time, but we will not combine your location information at various times to determine your whereabouts) to determine your location, so we can automatically recommend you goods or services that can be purchased in your area. This includes recommending you the cold storage closest to you and product information in your area.



2.2 Extended Business Functions Based on Cameras:



You can use this extended business function to complete video shooting, taking pictures, and scanning codes to achieve functions such as evaluation and after-sales communication.



2.3 Extended Business Functions Based on Image Upload:



You can upload your photos on Coldeal to realize the photo shopping function, comments sharing function and the evaluation function. We will use the photo you uploaded to identify the products you need to buy or use the evaluation that contains the image you uploaded.



2.4 Extended Business Functions Based on Voice Technology:



You can use the microphone directly for voice shopping or consultation and interaction with our customer service robot. In these functions, we will collect your recording content to identify your shopping needs and customer service and after-sales needs.



2.5 Extended Business Functions Based on Other Device Information:



In order to provide better products and / or services and improve user experience, we will collect device attribute information (including your hardware model, operating system version, and network device hardware address MAC), device connection information (browser type, network operator, and language used). We may associate the information collected from your various devices so that we can provide you with consistent services on these devices. We may associate your device information or phone number with your Coldeal account to improve the user experience and / or secure transaction security.



You understand and agree: we are committed to creating diverse products and services to meet your various needs. Due to the variety of products and services we provide to you, and the specific products / services that different users choose to use, correspondingly, the basic / extended functions and the type and scope of personal information collected and used will be different according to he specific product / service functions. In order to bring you a better product and service experience, we are continuously working to improve our technology, and we may launch new or optimized functions from time to time, which may need to collect and use new personal information or change the purpose or method of using personal information. In this regard, we will separately explain to you the purpose, scope and use method of the corresponding information by updating this privacy policy, pop-up window, page prompts, etc., and provide you with choices for you to consent on your own, and collect and use the information after your clear agreement. During this process, if you have any questions, comments or suggestions, you can contact us through the [Part 10] contact information provided by us, and we will answer you as soon as possible.



3. Personal Information We Obtain Indirectly



3.1 When a specific product is another product or service that serves Infinity or provides services to you together with Infinity's affiliated companies or its partners, you agree that we will receive, use, aggregate, and analyze your personal information you provided for Infinity’s other products and affiliated companies with your authorization according to actual business and cooperation needs.



3.2 We take the following two methods to indirectly obtain your personal information:



3.2.1 Obtained from other products or services operated by Infinity



Only if you agree in the specific privacy policy or prompt of the relevant products or services operated by Infinity that Infinity will integrate the personal information provided by the specific product or service with other data information available in Infinity, we will aggregate, analyze and process your personal information provided based on the specific product or service in Infinity, and provide it for other products or services operated by Infinity to serve you more conveniently and accurately. For example, we can use this data processing method to provide you with registration convenience, or to save you from repeating operations of submitting personal information, and to help you ensure the accuracy of the personal information you provide to Infinity. We will implement corresponding systems and measures in accordance with the requirements of existing laws and regulations, regulatory documents and relevant national standards, carry out personal information security impact assessment, and take appropriate personal information protection measures to protect the integrated personal information data.



3.2.2 Obtained by a third party outside Infinity



When we obtain your personal information from third parties outside Infinity, including Infinity’s affiliates and third-party cooperation agencies, we will make reasonable efforts in accordance with the requirements of existing laws and regulations, regulatory documents and relevant national standards to verify that those third-party partners have obtained your legal authorization to provide us with personal information and the specific scope and duration of the authorization. If we plan to use your personal information beyond your authorized scope, we will obtain your prior consent. At that time, Infinity will act as the authorized party of personal information to reach a new authorization license for your personal information use.



4. Other Personal Information Collecting Scenarios that Should Draw Your Attention:



4.1 In specific scenarios and according to the applicable rules, any text, photos, videos and other information submitted by you during the use of Coldeal forums or social interaction of some sections may contain your personal information. You may need to submit more personal information when consulting after-sales services. Information you actively provided to us when you participated in the questionnaire survey. Identity or authorization information you published on behalf of other parties (including but not limited to minors). Please note that the information collected and used in the above services may contain personal sensitive information (such as ID number, personal biometric information, bank account number, communication records and content, property information, credit information, whereabouts, accommodation information, Health and physiological information, transaction information, personal information of children under 14 years of age (inclusive), etc.). Therefore, please make sure that you have given specific, clear and unambiguous consent of voluntary choices based on the services you need.



5. Exceptions with Authorized Consent



According to relevant laws and regulations, collecting your personal information in the following situations does not require your authorized consent:

(1) Related to national security and national defense security;

(2) Related to public safety, public health, and major public interests;

(3) Related to crime investigation, prosecution, trial and execution of judgments, etc.;

(4) Out of the protection of the significant legal rights and interests of individual’s personal information or other individuals' lives and property when it is difficult to obtain your own consent;

(5) The personal information collected is disclosed to the public by yourself;

(6) Personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

(7) Necessary to sign a contract according to your requirements;

(8) Necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and handling failures of products or services;

(9) Other situations stipulated by laws and regulations.



6. Your Information from Third-party Sources



In the process of registering our account and using our services, we can obtain personal information about you from related parties, partners and other independent third-party sources with your authorization. For example, when you choose a third-party authorized login, we obtain the account information (avatar, nickname and other personal information) that you authorized to share from a third party, and bind your third-party account with your Coldeal account after you agree to this privacy policy, so that you can directly log in and use our products and / or services through a third-party account. We will use your personal information after confirming the legality of the source of personal information according to the agreement with the third party and in compliance with the relevant laws and regulations.



7. Your Information We Obtained during Your Use of Products andServices



We may collect the following information when you use our services:



7.1 Log Information:



When you use our services, the system may automatically collect technical information through cookies or other methods, including but not limited to:



(1) Device or software information, such as configuration information provided by your mobile device, web browser, network operator, or other programs used to access our services, your IP address, and version used by your mobile device.



(2) Information that you search or browse when using our services, such as the web search terms you use, the URL addresses of social media pages you visit, and other information and content details that you browse or request when you use our services.



(3) The information (metadata) contained in the content you upload through our services, such as the date, time, and location when posting a comment or uploading an image.



We will use this information to meet your requirements, provide related products or services, or protect the security of your account. You can stop our collection of your log information through system prompts, but it may prevent you from using some Coldeal features or affect your experience. For more information, please refer to this policy [Part V]: How do we use cookie technology.



7.2 Location Information:



When you turn on device location and use our location-based services, the system automatically collects information about your location, including:



(1) When you use our services through a mobile device with a positioning function, your geographic location information will be collected through GPS or WiFi.



(2) The real-time information provided by you or other users that contains your geographic location, such as the information about your location included in the account information you provided, shared information uploaded by you or others that shows your current or past geographic location, and geotagging information contained in photos shared by others or others.



You can stop our collection of your geographic location information by turning off the positioning function, but this operation may prevent you from using some of Coldeal's features and affect your experience.



8. Rules for the Use of Your Personal Information



8.1 We will use the collected personal information in accordance with the description and agreement of this privacy policy to realize the functions of our products and / or services. We will ask for your consent in advance，if we would like to use your personal information for other purposes not specified in this policy, or when the information collected for a specific purpose would be used for other purposes.



8.2 All personal information you provide when you use our products and / or services will continue to authorize us to use during your use of our products and / or services unless you delete or refuse our collection through system settings. When you cancel your account, we will stop using your personal information and delete your personal information or anonymize it after the minimum retention period required by law is met.



8.3 After collecting your personal information, we may perform automated data processing on your personal information. In this case, we will de-identify the data in accordance with the national general technical standards to form a user database. The use of information that meets de-identification standards does not violate your personal privacy or violate personal information protection policies. We have the right to analyze and commercialize user databases.



8.4 We will collect statistics on the usage of our products and / or services, and may share these statistics with the public or third parties to show the overall usage trends of our products and / or services. However, these statistics do not contain any identification information about you.



8.5 When we need to display your personal information, we will de-identify your information by adopting content replacement, partial concealment and other processing methods to protect the security of your information.



8.6 If we cease to operate Coldeal products and / or services, we will promptly stop continuing to collect your personal information, notify you of the suspension of operation in the form of one-by-one delivery or announcement, and delete or anonymize the personal information we hold. At the same time, we will also notify the entities that obtained your personal information from us as much as possible a request of deletion in a timely manner, or those entities shall obtain your independent authorization.



Ⅱ How Do We Share, Transfer and Publicly Disclose Your Personal Information



1. Sharing of personal information



1.1 We will not share your personal information with any company, organization or individual other than Infinity and its related parties, except for the following condition:



(1) Obtain your explicit consent or authorization in advance.



(2) Provide in accordance with applicable laws and regulations, legal process requirements, mandatory administrative or judicial requirements when necessary.



(3) To the extent permitted by laws and regulations, it is necessary to provide for the protection of Infinity, its related parties or partners, you or other users of Infinity or the public interest, property or safety from damage.



(4) To handle disputes or disputes between you and others at your request.



(5) Used based on academic research.

(6) Used for public interests in compliance with laws and regulations.



1.2 We may share your personal information with our affiliates. However, we will only share the necessary personal information and are bound by the purpose stated in this privacy policy. If our affiliates want to change the purpose of processing personal information, they will seek your authorization and consent again. For the list of our related parties, please refer to the announcement page [Zhonglengtouzi and JD Logistics Cooperation Agreement].



1.3 We may share some of your personal information with third parties such as partners to provide better customer service or user experience. For example, provide order information, account information, equipment information and location information to ensure the successful completion of the services provided to you. However, we will only share your personal information for legal, legitimate, necessary, specific and clear purposes, and only share the personal information necessary to provide services. Our partners have no right to use the shared personal information for any other purpose. Our partners include the following types:



(1) Codeal’s suppliers of transaction, payment, logistics and customer service. We may share your order information and necessary information related to the transaction with third parties that support our functions to fulfill your needs for purchasing goods or services from them. These supports include supply, logistics and distribution services, payment services, data processing, and after-sales services for us. The purpose of sharing this information is to realize the function of our products and / or services. For example, we need to share your order and order amount with the third-party payment institution to confirm your payment instruction and complete the payment, and provide your data to data processing service providers in order to provide you with personalized services.



(2) Third-party service providers or partners. We will send your personal information to third-party service providers or partners who support our business. These supports include the provision of technical infrastructure services (such as cloud storage and cloud services), statistical analysis services, etc.



1.4 For companies, organizations and individuals with whom we share personal information, we will sign strict confidentiality agreements with them and require them to process personal information in accordance with our instructions, this privacy policy and any other related confidentiality and security measures. In the use of personal sensitive data, we require third parties to use data desensitization and encryption technologies to better protect user data.



1.5 In order to comply with the law, enforce or apply our terms of use and other agreements, or to protect the rights, property and safety of you, other Coldeal users and Coldeal itself, such as to prevent fraud and other illegal activities and reduce credit risks, to the extent permitted by laws and regulations we may exchange information with other companies and organizations. However, this does not include selling, renting, sharing, or otherwise disclosing of personal information for profitable purposes in violation of the commitments made in this privacy policy.



2. Transfer of Personal Information



We will not transfer your personal information to any company, organization or individual, except for the following:



(1) Obtain your explicit consent or authorization in advance.



(2) Provide in accordance with applicable laws and regulations, legal process requirements, mandatory administrative or judicial requirements as necessary.



(3) When involving mergers, acquisitions, asset transfers, or similar transactions, if personal information transfer is involved, we will require new companies and organizations that hold your personal information to continue to be bound by this privacy policy, otherwise, we will require the company and organization to ask you for authorization again.



3. Public Disclosure of Information



We will only publicly disclose your personal information under the following circumstances and under the premise of adopting security protection measures that comply with industrial standards:



(1) According to your needs, we will only disclose the personal information you specify and in a way that you explicitly agree to.



(2) When it is necessary to provide your personal information in accordance with the requirements of laws and regulations, mandatory administrative enforcement or judicial requirements, we may publicly disclose your personal information according to the type of personal information and the method of disclosure as required. Under the premise of complying with laws and regulations, when we receive the above-mentioned request for information disclosure, we will request a corresponding legal document, such as a subpoena or investigation letter. We firmly believe that the information requested from us should be as transparent as possible within the scope permitted by law. We have carefully reviewed all requests to ensure that they have a legitimate basis and are limited to data obtained by law enforcement agencies for legitimate investigation purposes with legal rights. As permitted by laws and regulations, the documents we disclose are all protected by encryption keys.



Ⅲ How Do We Protect and Save Your Personal Information



1. Our Technologies and Measures to Protect Your Personal Information



We attach great importance to the security of personal information and take all reasonable and feasible measures to protect your personal information:



1.1 Data security technical measures



We will adopt security protection measures that comply with industry standards, including establishing reasonable system specifications and security technologies to prevent unauthorized access, use, and modification of your personal information to avoid data damage or loss.



Our network services use encryption technologies such as the transport layer security protocol, and provide browsing services through https and other methods to ensure the safety of user data during transmission.



We adopt encryption technology to encrypt and save users' personal information, and implement strict data access control to prevent data from being used illegally.



When using personal information, such as personal information display and personal information related calculation, we will use desensitization technology to enhance the security of personal information in use.



1.2 Other security measures we take to protect personal information



We manage and standardize the storage and use of personal information by establishing a data classification and grading system, data security management specifications, and data security development specifications.



We conduct comprehensive security control of data through confidentiality agreements, monitoring and auditing mechanisms of information contacts.



We established a data security committee and set up a full-time information protection department and a data security emergency response organization to promote and ensure the security of personal information.



Strengthen security awareness. We will also hold security and privacy protection training courses to strengthen employees' awareness of the importance of personal information protection.



1.3 Coldeal only allows employees and partners of Infinity and Infinity affiliates who are necessary to know this information to access personal information, and has set up strict access rights control and monitoring mechanisms for this. We also require all personnel who may have access to your personal information to fulfill their respective confidentiality obligations. If they fail to perform these obligations, they may be held accountable for legal responsibility or suspended from the cooperative relationship with Infinity.



1.4 We will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We will only retain your personal information for the period required to achieve the purpose stated in this policy, unless the retention period needs to be extended or permitted by law.



1.5 The Internet is not an absolutely secure environment, and communication methods such as e-mail, instant messaging, social software, etc. with other users cannot be determined whether they are fully encrypted. We recommend that you set complex passwords when using such tools, and pay attention to protecting the security of your personal information.



1.6 The Internet environment is not 100% secure, and we will do our best to ensure or guarantee the security of any information you send to us. If our physical, technical, or management protection facilities are damaged, thus resulting in unauthorized access to information, public disclosure, tampering, or destruction, and resulting in damage to your legitimate rights and interests, we will bear the corresponding legal responsibility.



1.7 We will regularly update and publish the relevant contents of reports such as security risks and personal information security impact assessments in accordance with laws and regulations and the requirements of competent authorities.



1.8 Security Incident Handling



When conducting online goods or services transactions with third parties through Coldeal, you will inevitably disclose your personal information, such as contact information or postal address, to the counterparty or potential counterparty. Please protect your personal information properly and provide it to others only when necessary.



In order to deal with the possible risks of personal information leakage, damage and loss, we have formulated a number of systems to clarify the classification and grading standards of security incidents and security vulnerabilities and the corresponding processing procedures. We have also established a special emergency response team, in accordance with the requirements of security incident handling specifications, to initiate security plans for different security incidents, conduct stop loss, analysis, positioning, formulate remedial measures, and trace and crack down with relevant departments.



In the unfortunate event of a personal information security incident, we will promptly inform you, in accordance with the requirements of laws and regulations, the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions of independent conduct for risks prevention and reduction, remedies for you, etc. At the same time, we will promptly inform you about the incident by email, letter, telephone, push notification, etc. When it is difficult to inform the personal information subject one by one, we will adopt a reasonable and effective way to release the announcement. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.



1.9 If you have any questions about our protection of personal information, you can contact us through the contact information agreed in [Part 10] of this policy. If you find that your personal information is leaked, especially if your account and password are leaked, please contact us immediately through the contact information agreed in [Part 10] of this policy so that we can take corresponding measures.



2. Preservation of Your Personal Information



2.1 All your personal information will be stored in the People's Republic of China. If you initiate or accept a transaction with an overseas entity and need to transfer your personal information overseas to complete the transaction, you are deemed to agree to transmit your personal information to the overseas entity involved in the transaction. If we or our service providers / partners need to transfer your personal information overseas while providing services, we will separately obtain your authorized consent and require the recipient to follow our instructions, this privacy policy and any other relevant confidentiality and security measures to deal with these personal information.



2.2 We will keep your personal information in the shortest time required by all laws and regulations in accordance with the relevant provisions of the laws and regulations of the People's Republic of China and the type and purpose of use of personal information. After the above personal information retention period is exceeded, we will delete or anonymize personal information.



2.3 If we terminate the service or operation, we will notify you at least thirty days in advance, and delete or anonymize your personal information after the service or operation is terminated and the requirements of relevant laws and regulations are met.



Ⅳ How Do We Protect Minors' Personal Information



2.4 Coldeal attaches great importance to the protection of personal information of minors. As a platform serving commercial trade, we do not accept minors creating their own user accounts in Coldeal.



2.5 If we find that the minor ’s parent or guardian actively provided the minor ’s information in the use of Coldeal or services, or we collected the minor ’s personal information without the prior consent of a verifiable parent or legal guardian, we will try to delete the relevant data as soon as possible.



Ⅴ How Do We Use Cookies and Similar Technologies



1. Use of Cookies and Similar Technologies



1.1 In order to realize the personalized requirements of your online experience and a more relaxed access experience, we will send one or more small data files or similar technical files called Cookies to your computer or mobile device. The cookies assigned to you are unique, and they can only be read by the Web server that the Cookies published in your domain. We send you cookies to simplify your repeated login steps, store your shopping preferences or products in your shopping cart, so that then provide you with shopping preferences, help you optimize the selection and interaction of ads, and help judge your login status and account or data security.



1.2 We will not use cookies for any purpose other than those described in this privacy policy. You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer. Most web browsers will automatically accept cookies, but you can usually modify your browser settings to reject cookies according to your needs. In addition, you can also clear all cookies saved in the software. But if you do this, you may need to change the user settings each time you visit Coldeal, and the corresponding information you have recorded before will also be deleted, and may have a certain impact on the security of the services you use. For details on how to change the browser settings, please visit the relevant settings page of the browser you are using.



2. Do Not Track



Many web browsers are equipped with Do Not Track function, which can issue Do Not Track requests to websites. At present, major Internet standards organizations have not established policies to regulate how websites should respond to such requests. But if your browser has Do Not Track enabled, then we will respect your choice.



Ⅵ How Do You Manage Personal Information



You can access and manage your personal information in the following ways:



1. Access Your Personal Information



Unless otherwise stipulated by laws and regulations, you have the right to access your personal information. You can access your information by yourself in the following ways:



1.1 Personal profile information. If you wish to access or edit the basic personal profile information in your account, you can log in to your account and execute such operations through "Member Center-Me-My Profile-Edit Information" or "Member Center-Account Management-Enterprise Information".



1.2 Account Security Information. If you want to check or change the binding information or change the password, you can log in to your account through "Member Center-Me-My Profile-Edit Information", "Member Center-Account Management-Enterprise Information" or "Member Center-Account Management-Security Settings " to perform such operations.



1.3 Order information. You can log in to your account to access your purchase and sale order records through "Member Center-Order Management".



1.4 Cold storage management information. You can log in to your account to access your cold storage contract information, in-storage information, ex-storage information, butt joint information, monthly bill information through "Member Center-Cold Storage Management".



If you cannot access such personal information through the above path, you can contact us at any time through the contact information in [Part 10]. We will reply you within 15 days.



For other personal information generated during your use of our products or services, we will provide you with relevant arrangements in accordance with term "8" in response to your above request "



2. Correct or Supplement Your Personal Information



2.1 When you find that we have processed your personal information in error, out of date or incompletely, you should make changes or updates through the path listed in point 1 of this article. If you are unable to update your personal information through the above methods, you can contact us at any time through our online customer service, telephone customer service or email method on this website, and we will send you feedback of your application within 15 days after receiving your notification.



2.2 In particular, please pay attention to verifying the truthfulness, timeliness, completeness and accuracy of the personal information you submit, otherwise it could be unable for us to contact you effectively and unable to provide you with some services.



2.3 If we have reasonable reasons to suspect that the information you provided is wrong, incomplete, or untrue, we have the right to ask you or notify you to correct it, and even suspend or terminate the provision of some services to you.



2.4 Although we allow you to access and modify your personal information as much as possible, some of your personal information cannot be accessed and changed. This information mainly includes account information (including account ID, mobile phone, WeChat, QQ and other account to login), mainly because of network transaction security and determining the target that network products and services provide for.



3. Delete Your Personal Information



You can delete some of your personal information through the path listed in point 1 of this article.

In the following situations, you can submit a request to us to delete personal information:



(1) If our handling of personal information violates laws and regulations.

(2) If we collect and use your personal information without your explicit consent.

(3) If our handling of personal information seriously violates the agreement with you.

(4) If you no longer use our products or services, or you actively cancel your account.

(5) If we no longer provide you with products or services forever.



If we decide to respond to your request for deletion, we will also notify the subject who obtained your personal information from us as much as possible, and request that it be deleted in time, unless otherwise stipulated by laws and regulations, or these subjects obtain your independent authorization.



When you delete information from our service, we may not immediately delete the corresponding information from the backup system, but will delete the information when the backup is updated.



4. Scope Change of Your Authorized Consent



You can change the scope of the authorization agreement by changing the device or browser function settings, changing Coldeal's setting options, or contacting customer service via dial 4000-666-591.



In particular, if you do not want to accept the commercial promotional information we sent to you, you can reply for cancellation through the unsubscribe method clearly indicated on the promotional email or short message.



When you withdraw your consent, we will no longer continue to collect and use the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out based on your authorization.



5. Personal Information Subject Account Cancellation



You can contact us to submit an application for account cancellation through the contact information in [Part 10].



After you actively cancel your account, we will stop providing you with products or services. Unless otherwise stipulated by laws and regulations, your personal information will be kept for one month after the date of cancellation of your account or other required period stipulated by laws and regulations. We promise that this is the shortest period that your personal information must be kept in Coldeal Mal to guarantee your consumer rights in Coldeal. When your personal information exceeds our retention period, we will delete or anonymize your personal information.



6. Personal Information Acquisition by Personal Information Subject



You have the right to request through the contact information in [Part 10] a copy of your personal basic information, personal identification information, personal health physiological information and personal education and work information collected by us.



Under the premise of technical feasibility, such as data interface matching, we can also directly transfer your copy of the above personal information to the third party you specify according to your requirements.



7. Constrained Information’s System Automatic Decision



In some business functions, we may make decisions only based on by non-manual automatic decision-making mechanisms including information systems, algorithms, etc. If these decisions significantly affect your legal rights, you have the right to ask us to explain, and we will also provide appropriate relief.



7. Respond to Your Above Request



To ensure safety, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request.



We will respond within 15 days. If you are not satisfied, you can also initiate a complaint through customer service via dial 4000-666-591 .



For your reasonable request, we will not charge a fee in principle, but for repeated requests that exceed the reasonable limit, we will charge a certain cost as appropriate. For those requests that are unreasonably repetitive, require too many technical means (for example, need to develop new systems or fundamentally change existing practices), pose a risk to the legal rights of others or are very impractical (for example, involving information stored on backup tapes), we may refuse them.



In the following situations, as required by laws and regulations, we will not be able to respond to your request:



(1) Related to national security and national defense security.

(2) Related to public safety, public health, and major public interests.

(3) Related to criminal investigation, prosecution, trial and execution of judgments, etc.

(4) There is sufficient evidence that the subject of personal information is subjectively malicious or abuses his rights.

(5) Responding to your request will result in serious damage to the legal rights of you or other individuals and organizations.

(6) Trade secrets are involved.



Ⅶ HowYour Personal Information is Transferred Globally



The personal information we collect and generate during our operations in the People's Republic of China is stored in China, except for the following situations:



(1) The laws and regulations have clear provisions.

(2) Obtained your explicit authorization.

(3) Personal active actions conducted such as cross-border transactions via the Internet.



In response to the above circumstances, we will ensure that your personal information is adequately protected in accordance with this privacy policy and the requirements of Chinese laws and regulations on data outbound.



Ⅷ Notification and Revision



8.1 In order to provide you with better services and with the development of Coldeal's business, this privacy policy will be updated accordingly. However, without your explicit consent, we will not reduce your rights under this privacy policy. We will issue an updated version on Coldeal and remind you of the update of relevant content through the website announcement or other appropriate means before it becomes effective. Please also visit Coldeal to keep abreast of the latest privacy policy.



8.2 For major changes, we will also provide more prominent notifications (we will include but not limited to emails, text messages or special reminders on the page viewed to explain the specific changes to the privacy policy).

The major changes referred to in this policy include but are not limited to:



(1）Our service model has undergone major changes, such as the purpose of processing personal information, the type of personal information processed, and the use of personal information, etc.

(2) We have undergone major changes in the ownership structure, organizational structure, etc. Such as business adjustments, bankruptcy mergers and acquisitions, etc., which causes to the change of owners.

(3) The main objects of personal information sharing, transfer or public disclosure have changed.

(4) Significant changes in your rights to participate in the processing of personal information and how you exercise them.

(5) When responsible department dealing with personal information security, contact information and complaint channels changes.

(6) When the personal information security impact assessment report indicates that there is a high risk.



Ⅹ How to Contact Us

If you have any questions, comments or suggestions about this privacy policy or your personal information related matters, please contact us by calling any of our 4000-666-591 customer service or Coldeal publicized other methods such as e-mail.



Under normal circumstances, we will reply within fifteen days. If you are not satisfied with our response, especially if our personal information processing behavior damages your legitimat rights and interests, you can also make a complaint or report to the regulatory authorities suchas CAC, China Telecom, Public Security Bureau and Bureau of Industry and Commerce.





Appendix 1: Definition



1. Personal Information

Personal information refers to all kinds of information recorded in electronic or other ways that can identify the identity of a specific natural person or reflect the activities of a specific natural person, alone or in combination with other information.



2. Personal Sensitive Information

Personal sensitive information refers to personal information that, once leaked, illegally provided or misused, may endanger the safety of people and property, easily lead to damage to personal reputation, physical and mental health or discriminatory treatment.